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V. DISCIPLINARY ACTION
             The Management of SEKO, and/or of SEKO’s Partners and/or Agents (if affected) will determine the
             appropriate action in an investigation regarding potential violation of the Code of Conduct or any alleged
             misconduct that falls within the purview of the principles set forth herein. Violations of SEKO’s Code of
             Conduct, or of its other policies and procedures that are aligned with this Code of Conduct, will be grounds
             for disciplinary action up to and including termination, or in the case of a Partner and/or Agent, the
             contract or agreement with SEKO may be terminated or suspended. All Employees, Partners, and
             Agents will be held to the same standards of conduct described herein.

             VI.  ACKNOWLEDGEMENT & PUBLISHING OF THE CODE OF CONDUCT
             Each Employee, Partner, and Agent will be required to review the Code of Conduct via SEKO intranet or
             on SEKO’s public website at www.sekologistics.com. Any questions regarding the terms of this Code of
             Conduct should be sent to the email address set forth herein.


             SECTION 11

             ANTI-SLAVERY AND HUMAN

             TRAFFICKING STATEMENT



             I. PURPOSE
             SEKO has a strong and unwavering commitment to   suppliers, subcontractors or business partners
             prohibiting human trafficking and slavery by any of   worldwide (collectively “Suppliers”). SEKO strongly
             its business entities, employees, and other parties   opposes any use of slavery or human trafficking in the
             associated with SEKO. In compliance with the law, and   distribution of its own products, or its client’s products,
             to effectuate SEKO’s commitment to prohibiting these   and fully supports the promotion of ethical and lawful
             practices, this Anti-Slavery and Human Trafficking   business practice within our workplace.
             Statement (hereafter referred to as the “Anti-Slavery
             Statement”) serves to ensure a work environment
             that is free from human trafficking, forced labor and   II. SCOPE
             unlawful child labor (Slavery and Human Trafficking).   This policy covers all employees of SEKO and all of
             SEKO strongly believes that it is responsible for   its subsidiaries or entities controlled by SEKO. In the
             promoting ethical and lawful employment practices   event that anything in this policy may conflict with
             amongst the SEKO group of companies. These       local law, local law will control the interpretation and
             practices are also required to be followed by our   application of this policy statement.


































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